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You have a few examples right here in this thread, and you don't care. As usual.
We understand that civil rights aren't a binary category, and that different people and different nations guarantee them to different degrees and in different ways. The same is true of free speech.
What NGO is saying is that Europe's definition of free speech, to the extent that it does not block Right to be Forgotten, is not expansive enough.
It is meaningless to talk about whether or not "technically" Europe has free speech, in the same way that it is meaningless to talk about whether or not technically China has a right to privacy. When Americans say that European nations don't have real 1A rights, they're saying that Europe does not guarantee those rights strongly enough, based on an idea that these rights are intrinsic and are protected by the state, not granted or defined by the state.
The trouble with strong 1A supporters is that they pretend like the free speech restrictions in the US are not both arbitrary and frequently racially biased due to the slow functioning of the justice system. You cannot shout fire in a crowded theatre, you cannot make direct death threats, you cannot incite riots, you cannot share information as an attorney or as a government agent etc. There's tons of exceptions that have only an arbitrary distinction from European-style exceptions. A common point with all these 1A exceptions is that they apply to the benefit of property owners and people who are otherwise privileged.
I.e. Americans who are strong 1A supporters think these rights are intrinsic and protected by the state because the exceptions to free speech pretty much all work in their favour, so they don't mind them.
Um, Yes, you can shout fire in a crowded theate.
https://www.washingtonpost.com/news/volokh-conspiracy/wp/201...
If no one panics, then you generally don't get charged with anything, except possibly trespassing.
Also I'd like to point out that many of the landmark cases establishing the doctrine of "imminent lawless action" were defending the rights of far-left political activists. I'm not sure I buy into your "free speech for the privileged" theory.
https://en.wikipedia.org/wiki/Schenck_v._United_States
Also, I'm not sure that I see how your links support your claims. The first and third were ruled against the far-left activist, and the second was overturned but on the 14th amendment (not 1st).
In America, there are active efforts by members of the government to classify Antifa as a hate group. Facebook famously got a lot of flack over their decisions about whether or not "white men" count as a protected category. And again, I wouldn't be surprised if there are people on HN who disagree over whether or not protected categories should be extended to historically privileged groups.
The thing is, ignoring intrinsic rights, both free speech and censorship are still neutral tools. Regardless of what direction you lean, there will be efforts by the powerful to use the tools you embrace to suppress others. The conflict is figuring out what the proper balance is to make it difficult to abuse those neutral tools.
But it's not simple to claim, "people should only be allowed to say good things," for the same reason why it's not simple to claim, "only the government should be able to unlock my phone." You have to figure out where to draw a line between encryption and warrants, bearing in mind that corrupt individuals will take advantage of both.
The examples that GP linked were decided against far-left activists based on the idea that free speech wasn't absolute. Many of them are regarded as negative precedents now, moments in history that we're ashamed of. I'm ashamed that America tried to use the law to prevent people from protesting the draft.
Of course free speech isn't absolute. But that doesn't mean that discussions about how far we should go are meaningless, or that anyone who suggests that a law is too restrictive is actually just a secret absolutist. Historically, free speech rights in the US have grown over time, not shrunk. That suggests that as far the US is concerned, we think that historically we didn't take those rights far enough -- and usually whenever we put limits on free speech we did so to the exclusion of good faith protesters and minorities.
This makes many 1A advocates nervous about reintroducing those limits, because a large portion of the examples we have about enforcement of those limits in the past were used to suppress and harm activists.
Of course it's reasonable to disagree on that front; you probably have experiences in your own life that have convinced you that the European model is better. Those differing experiences are a good reason for us to look for laws that respect national autonomy where possible.
https://en.wikipedia.org/wiki/Laws_against_Holocaust_denial#...
https://en.wikipedia.org/wiki/Laws_against_Holocaust_denial#...
https://en.wikipedia.org/wiki/Laws_against_Holocaust_denial#...
Starting with that Germany example: there's a common pattern of saying "all Germany bans is Nazi propaganda, surely you don't object to that?", but it's not actually true. Germany bans 'insult', a category which produces upwards of 20,000 convictions per year. Disparaging the symbols of the state is prohibited, and a lèse-majesté law was present and occasionally enforced until January 2018. Distributing pornographic writing remains restricted, as does insulting a faith in a manner that could disturb the peace - both classes of law which are infamous around the world for enabling biased prosecutions along religious lines. And when it comes to the mechanisms of speech, Germany set the precedent on the infamously terrible 'link tax' rule being floated for the EU as a whole.
On to the question of the US First Amendment: 1A critics often have a blindspot about how the presence of extremely strong free speech protections anywhere helps people everywhere in the digital era.
The UK, for example, has ludicrous internet censorship standards ranging from banning hosting for large classes of content to ISP-level site blocking. (And it turns out those powers have been consistently used to enable copyright abusers and restrict LGBT content, exactly like free speech advocates predicted.) But the situation in the UK isn't terribly bad - because offending content is hosted under US laws and served back to the UK! We see this pattern all over. Turkish dissidents graffiti the IPs of US-hosted content to bypass DNS blocks. Chinese firewall-bypassers end up on Taiwanese and US sites for regime-critical news. Bangladeshi student protestors share videos on Firechat that eventually end up on Reddit under 1A protections. The 'right to be forgotten' itself acts as a bar to cursory investigation instead of full information hiding because US-based search retains removed results.
If free speech absolutism means saying "German and Chinese speech laws are equally unacceptable", then sure, that's absurd. But jumping from "Germany isn't totalitarian" to "1A stringency is needless because Germany's fine" is the same sort of mistake in the opposite direction.